Joseph (Jud) B. Judkins

Partner

Baker & McKenzie LLP

Washington, DC

T + 1 202 835 6137
F + 1 202 416 7137

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Biography

Joseph "Jud" Judkins is a partner in Baker McKenzie’s Tax Practice Group and serves on the group’s Tax Controversy Steering Committee. Jud focuses on federal tax controversy matters at every phase of a dispute, including audit, IRS Appeals, and litigation. The application of administrative law principles to Treasury regulations and IRS guidance is a core component of his practice. Jud advises clients on a broad spectrum of international and domestic tax matters, including challenges to the validity of regulations, participation in the agency rulemaking process through the submission of comments and testimony at public hearings, the scope and application of TCJA regulations, transfer pricing disputes, tax statutory and regulatory interpretation, and other domestic and international tax issues. Jud previously clerked at the U.S. Tax Court and served in the U.S. Navy JAG Corps.

Practice Focus

Jud concentrates on tax dispute resolution.

Representative Legal Matters

Altera Corp. & Subsidiaries v. Commissioner, 145 T.C. No. 3 (2015), rev’d, 926 F.3d 1061 (9th Cir. 2019) (challenge to the validity of transfer pricing regulations).
FedEx Corp. & Subsidiaries v. United States, U.S. District Court for the Western District of Tennessee, No. 2:20-cv-02794 (challenge to the validity of regulations under section 965)
Guardian Industries Corp. v. United States, US District Court for the District of Michigan, No. 4:16-cv-1911 (suit for refund of penalties for failure to file information returns of foreign corporations).
Gubser v. Internal Revenue Service, US District Court for the Southern District of Texas, No. 5:15-cv-00298, US Court of Appeals for Fifth Circuit, No. 16-40948 (declaratory judgment suit regarding the standard for proving a willful FBAR penalty).
Maze v. Internal Revenue Service, US District Court for the District of Columbia, No. 1:15-cv-01806, US Court of Appeals for the D.C. Circuit, No. 16-70496 (suit challenging the validity of rules under the Offshore Voluntary Disclosure Program).
Whirlpool Financial Corp. v. Commissioner, U.S. Court of Appeals for the Sixth Circuit, Nos. 20-1899, 20-1900 (application of Subpart F Manufacturing Branch Rules to Mexican manufacturing company)

Admissions

U.S. Court of Appeals, Sixth Circuit~United States (2020)
U.S. District Court, Western District of Tennessee~United States (2020)
U.S. Supreme Court~United States (2016)
U.S. Court of Appeals, Ninth Circuit~United States (2016)
U.S. Court of Appeals, Fifth Circuit~United States (2016)
U.S. District Court, Eastern District of Michigan~United States (2016)
U.S. Court of Appeals, D.C. Circuit~United States (2016)
U.S. District Court, District of Columbia~United States (2015)
Tennessee~United States (2014)
U.S. Tax Court~United States (2009)
District of Columbia~United States (2006)
North Carolina~United States (1999)

Education

Georgetown University (LL.M. Taxation Distinction) (2008)
Wake Forest University (J.D. cum laude) (1999)
University of Tennessee (B.A. summa cum laude) (1996)

Languages

English

Publications

Author, “The Rise of Footnote 9 (And Why Some TCJA Regulations Fail Chevron Step One),” TAXES the Tax Magazine, March 2020

Co-author, "Chamber of Commerce Shows the Vulnerability of In Terrorem IRS Notices," TAXES the Tax Magazine, March 2018

Author, “The Upsides and Downsides of Ending Chevron Deference,” Tax Notes, The Star Forum, March 2017

Co-author, "Treasury Issues Temporary and Final Code Section 385 Regulations," Baker & McKenzie, Tax News and Developments Client Alert, November 2016

Baker & McKenzie LLP is a Limited Liability Partnership organized under the laws of the State of Illinois (USA) and is a member of Baker & McKenzie International, a Verein organized under the laws of Switzerland.